Safety & Compliance · SOP

Hazard Communication WHMIS/GHS Chemical Inventory Audit

This procedure defines the systematic approach for auditing all chemical inventories against WHMIS 2015 (GHS) requirements — ensuring every container is labelled, every SDS is current, and every storage location is compliant with Canadian federal and provincial regulations.

Estimated Time

180 min

Difficulty

Intermediate

Regulation

WHMIS 2015 (GHS)

Version

1.0

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Purpose

To establish a standardized, auditable protocol for conducting a complete chemical inventory audit that ensures full compliance with the Hazardous Products Act and WHMIS 2015 (GHS) regulations. This SOP enables organizations to systematically verify that every hazardous chemical in the workplace has a current Safety Data Sheet (SDS), is labelled in accordance with GHS requirements, and is stored in a manner that minimizes risk to workers and the environment.

Regular audits reduce the likelihood of regulatory fines, improve emergency response capability, and form the backbone of a defensible hazard communication program under Part 5 of the Canada Occupational Health and Safety Regulations (COHSR) and provincial equivalents such as WorkSafeBC OHS Regulation Part 5.

Scope

This procedure applies to all operational areas, storage rooms, satellite accumulation zones, maintenance shops, laboratories, and point-of-use locations where hazardous chemicals — as defined by the Hazardous Products Regulation (HPR) — are received, stored, handled, or used. It covers:

Bulk storage tanks, drums, totes, and portable containers
Secondary (decanted) containers used for daily operations
Laboratory chemicals, reagents, and analytical standards
Cleaning agents, solvents, lubricants, and industrial process chemicals
Waste hazardous materials awaiting disposal (satellite accumulation)

Excluded: Consumer products used in office areas that are exempt under WHMIS 2015 (e.g., office cleaning supplies in original packaging with no workplace exposure risk).

Safety Precautions

PPEWear chemical-resistant gloves (nitrile or neoprene), safety goggles with splash shield, and a lab coat or chemical apron during all physical inventory walkthroughs. Upgrade to a full-face respirator with organic vapour cartridges if opening unknown containers is required.
VENTEnsure all storage areas are adequately ventilated. Do not enter confined chemical storage rooms without atmospheric monitoring (O₂, LEL, H₂S).
SPILLHave a fully stocked chemical spill kit immediately accessible. If a leaking or damaged container is discovered, isolate the area, don appropriate PPE, and manage the spill per the site-specific spill response plan before proceeding.
SEGREVerify chemical segregation during the audit — incompatible materials (e.g., oxidizers with flammables, acids with bases) must be physically separated. Never assume existing storage is correct.
LOTOIf the audit requires accessing locked storage rooms or moving palletized inventory, apply lockout/tagout to any powered material handling equipment before performing inspections or label scans.

Required Tools & Materials

Master chemical inventory list (digital or printed from the management system)
Current WHMIS 2015 Safety Data Sheets (SDS) for all chemicals on site — either physical binders or digital repository
WHMIS 2015 GHS label templates and a thermal label printer or pre-printed GHS labels
Barcode scanner, tablet, or mobile device with inventory management app
Digital camera or phone camera for documenting container condition and labelling issues
Chemical-resistant PPE (gloves, goggles, apron, respirator if required)
Clipboard, audit log sheets, and permanent markers (oil-resistant, solvent-proof)
Chemical spill kit (portable 20L pail with absorbents, neutralizers, and waste bags)
Incompatible chemical segregation reference chart (GHS storage colour code guide)
Torx or hex key set for opening locked storage cabinets if needed

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Procedure: Step-by-Step

1 Pre-audit preparation. Gather the current master chemical list, all SDS binders (or digital SDS database), and the most recent version of the Hazardous Products Regulation. Confirm the number of storage locations, satellite accumulation areas, and point-of-use stations. Print or load the audit checklist.

2 Physical walkthrough of all workspaces. Visit every storage area, maintenance bay, lab, and satellite accumulation zone. Scan or photograph every chemical container present. Record the product identifier, supplier, container size, quantity on hand, and physical condition (leaking, rusted, dented, illegible label).

3 Cross-reference containers with SDS records. For each chemical identified, locate the corresponding SDS. Verify the SDS is the current version — issued within the last 3 years or revalidated by the supplier. Flag any chemical with an expired or missing SDS.

4 Verify container labelling compliance. Check that every container has a legible WHMIS 2015 compliant label. The label must include: product identifier, supplier identifier, GHS hazard pictograms (red diamond), signal word (Danger/Warning), hazard statements (H-phrases), precautionary statements (P-phrases), and any supplemental label elements. Secondary (decanted) containers must have a workplace label with the product identifier and precautionary measures.

5 Identify missing or expired SDS records and labelling deficiencies. Compile a non-compliance log. For each deficiency, record the chemical, location, container type, and specific issue (e.g., "SDS last revised 2019 — expired," "No GHS pictograms on drum," "No workplace label on spray bottle").

6 Update the master inventory log. Enter all verified data into the chemical inventory management system. For each entry, annotate: location (building/room/rack), UN number (if applicable), SDS expiry date, label compliance status, and storage segregation group (flammable, oxidizer, corrosive, etc.). Generate a revised master list.

7 Remediate all deficiencies immediately. Print and apply replacement GHS labels on containers with missing or illegible labels. Contact suppliers for missing or expired SDS — request the current version in writing. Segregate any incompatible chemicals found stored together. Dispose of leaking or unidentifiable containers as hazardous waste.

8 Generate non-compliance report and corrective action plan. Document every deficiency with photographs and the corrective action taken. For any remaining open items (e.g., supplier has not yet sent an updated SDS), assign a responsible person and a target completion date. Submit the report to the Joint Health and Safety Committee (JHSC) or the competent person.

9 Final sign-off and record retention. Obtain sign-off from the JHSC co-chair or site safety manager. Archive the completed audit file — including the raw walkthrough data, corrected SDS records, label photos, and the corrective action plan — for a minimum of 5 years (or as required by provincial OHS regulation). Schedule the next audit on a 12-month cycle.

Hazard Communication WHMIS/GHS Chemical Inventory Audit

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